City of Albemarle Wastewater Treatment Plant - Executive Summary

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City of Albemarle 
Albemarle, NC 
 
Executive Summary 
 
The City of Albemarle has implemented a comprehensive program to safely manage chlorine at its water and wastewater treatment plants located in and near the City of Albemarle. There have been no chlorine incidents in the most recent Five-Year history period at the plants. 
 
To comply with the EPA Risk Management Program (RMP), the initial step was to develop a prevention program as required by the RMP and by the OSHA Process Safety Management (PSM) regulations. This prevention program was initiated at the Plants using a consulting organization. An RMP/PSM Compliance Manual was developed for the site. 
Key items included in the manual were: 
 
- Written site-specific procedures for Employee Involvement, Management of Change, Incident Investigation, Pre-Startup Reviews and Self-Audits. 
 
- Chlorine safety information as required by the regulations 
 
Next, these additional steps were implemented to bring the PSM program to full compliance: 
 

Training on PSM and its key components including Management of Change, Mechanical Integrity and Incident Investigation. 
 
-Conducting  Process Hazards Analyses for the two chlorine processes 
 
-Developing Standard Operating Procedures for safe Chlorine Management 
 
-Developing a Maintenance Program for the chlorine systems at each plant 
 
-Developing an initial Emergency Response Plan 
 
-Training in support of the certification of operators 
 
The superintendent, chief operators and several plant operators are meeting several times per year to review and update procedures and to maintain compliance with all aspects of the PSM/RMP regulation. 
 
In addition to PSM compliance, the plants have implemented a number of programs to improve the safe handling of chlorine. 
 
- The chlorine delivery system at the Tuckertown Water Treatment Plant was designed to use a vacuum process when it was constructed in 1992. This new process has proven to significantly improve chlorine safety by placing mo 
st of the cylinder system under vacuum. Any leak will result in air leaking into the system as compared to chlorine escaping the system. 
 
- The chlorine emergency response plan has been upgraded at all plants. The services of a regional hazardous material response team have been obtained to response to all chlorine incidences. 
 
Future projects will evaluate using a vacuum chlorine process or alternatives to chlorine for disinfecting at the other two plants. 
 
To further understand chlorine risks, Operations Excellence Consulting, Inc., a safety consulting firm was contracted to conduct "Offsite Consequence" Modeling Analysis, as required by EPA's Risk Management Program. Both "Worst Case" and "Alternative Case" chlorine release scenarios were studied for each site. 
 
The results showed that the risk of chlorine exposure varies depending on the plant's location: 
 
- The Wastewater Treatment Plant is located is located approximately 5.5 miles south of the Albemarle city center. The plant is 
located in a low-lying area adjacent to the banks of Long Creek, which is approximately 375 feet west and 15 feet topographically downgradient from the plant. The plant's elevation is 415 feet above mean sea level. The closest public receptors are located to the west of the plant and are situated in areas that are topographically upgradient from the chlorine storage areas.  Chlorine is classified as a heavier-than-air gas, and as such tends to naturally flow downhill towards low-lying areas.  In a little-to-no wind situation at the plant, a chlorine release would tend to flow eastward down to the creek, then remain in or around the water until dissipated. 
 
- The Tuckertown Water Treatment Plant is located at 36576 Highway 49,  approximately 10 miles north of the Albemarle city center. The plant is located approximately 1,500 feet west of the Tuckertown Reservoir, which is an impounded section of the Yadkin River. The plant's elevation is approximately 80 feet above the elevation of th 
e reservoir.  Chlorine is classified as a heavier-than-air gas, and as such tends to naturally flow downhill towards low-lying areas.  The land areas to the west, north and south are topographically upgradient from the plant, creating a natural berm effect, and creating a defined channel which would tend to direct any chlorine release eastward toward the reservoir. There is a heavy growth of trees and vegetation on the shoreline. Thus, in a little-to-no wind situation or for winds from the northwest, west, southwest, a chlorine release would tend to flow to the reservoir area, where it will initially be contained at the tree-lined shore and then remain in or around the water until dissipated. 
 
- The Hwy 52 Water Treatment Plant is located at 2510 Highway 52 North,  approximately 3.3 miles north of the city center The plant is located to the east and topographically upgradient from Highway 52.  Since chlorine is classified as a heavier-than-air gas, except in the case of a very strong w 
ind from the west, any chlorine release will tend to flow westward down toward the highway.  To the east is a small, circular, man-made reservoir whose elevation is slightly higher than the plant.  Little Long Creek is located approximately 2,500 feet east and 145 feet topographically downgradient from the plant.  If a chlorine release were to occur during a period of very strong winds from the west, the release may be blown toward the creek, then remain in or around the water until dissipated.  
 
In addition to Process Safety Management, the organization has an active safety program. The City of Albemarle has had an active Safety Committee. The committee meets monthly with representatives from each function and each site.  The committee's duties include reviewing new safety procedures, accident investigations, safety surveys and safety communications.  
 
Within the Utilities Department, there are monthly safety meetings conducted by each plant. There is a review on an OSHA subject or a  
discussion on a specific water or wastewater safety issue.  
 
The Utilities safety program involves the following activities: 
 
- Conducting accident reviews for prevention/minimization; 
- Conducting safety inspections for all facilities; 
- Disseminating safety information to Utilities  staff; 
- Preparing and conducting safety training program including such topics as hazard communication, personal protective equipment, confined space and lockout/tagout; 
- Verifying performance of  training programs; 
- Addressing safety issue referrals; 
- Identifying mandatory regulatory agency-required safety training needs;  
- Recognizing exemplary safety performance 
 
As a result of our programs, the plants have had a strong safety record with no loss time accident over the past three years. We plan to continue our emphasis on safety to maintain and improve our safety performance. 
 
Report by: 
 
Gary Smith 
Plants Superintendent 
City of Albema 
rle, North Carolina
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